CHAPTER 4

Developing a Corporate Social Responsibility Strategy

The collection and analysis of information during the assessment stage is valuable in and of itself in that it necessarily increases awareness of the potential role of social responsibility in the company’s business activities allows the company to benchmark its corporate social responsibility (CSR) profile against the efforts of competitors and learn more about the needs and expectations of its stakeholders and identify and prioritize its own unique set of CSR issues and actions. However, the primary purpose of the assessment is to provide the leadership team with the information necessary for it to develop a CSR strategy. As with any other strategic initiative, CSR activities must be institutionalized into the organization in order to be sustainable and thus it is essential that CSR be seen to be inherent in the organizational culture and adopted as part of the company’s long-term strategy and decision making rather than being seen as an “add on” that can be discarded when circumstances change (e.g., when an economic downturn creates pressures to divert resources away from sustainability initiatives).¹ Like any other strategy, a CSR strategy reflects decisions among multiple potential CSR projects and provides a path for implementation, assigns roles and responsibilities throughout the organization, establishes timetables for the completion of various tasks and incorporates metrics to measure progress and performance. The CSR strategy should reflect the consideration of the company’s strengths and weaknesses and the opportunities and threats identified during the assessment phase and must also be aligned with the company’s core values and standards.

While there are certain elements that should be included in a formal version of a company’s CSR strategy, the process itself should remain fluid and flexible in order to elicit participation from all of the company’s stakeholders in a dialogue that begins by focusing on just what CSR means to the company. Strategy development must be proactively led by the senior leaders of the company since they are responsible for setting the appropriate tone, allocating the resources necessary to implement the strategy once it is in place and ensuring that the strategic targets are understood by everyone in the organization and embedded into the company’s culture and systems. When developing the strategy, attention should be paid to creating a record of meetings and other discussions that were integral to development process since the record itself can be a valuable resources for preserving ideas and providing evidence to stakeholders that serious consideration has been given to CSR strategy and decision making.

The strategy itself should include a mission statement, goals and commitments, and policies for each of the CSR dimensions covered by the strategy (e.g., financial, environmental, labor, community, and supply chain responsibility), key performance indicators, a clear allocation of responsibilities for the implementation of the strategy and procedures for reporting on progress, and regular evaluation of the strategy. As the strategy moves toward finalization, it should circulated to key stakeholders for their input, a step that not only improves the strategy but creates a sense of participation among stakeholders that will ultimately garner their support. Once the company is actively engaged in implementing the strategy, it is essential to measure and assure performance, engage stakeholders and report on performance, both internally and externally. The CSR leadership team must evaluate performance, identify opportunities for improvement, and engage with stakeholders on implementing changes.

According to Hohnen and Potts, a good CSR strategy typically identifies the overall direction for where the firm wants to take its CSR work; the stakeholders and their perspectives and interests; a basic approach for moving ahead; specific priority areas; a timeline for action, responsible staff, and immediate next steps; and a process for reviewing and assuring outcomes.² As for the process of developing a CSR strategy, Hohnen and Potts suggested the following steps³:

Building Support With Senior Management and Employees

CSR initiatives will not be successful without the strong and continuing support of senior management and employees. Hopefully the collection of information during the assessment process, including dialogue among the members of the leadership team and between those team members and employees and other stakeholders, has built an awareness of the potential opportunities associated with socially and environmentally responsible business activities. This awareness should serve as the foundation for support of the development and implementation of the actual CSR strategy. In particular, support needs to be gathered for sometimes difficult changes in product and service offerings and changes to decision-making processes and organizational structure. Change management is the responsibility of senior management and senior managers must be willing to add CSR activities to their already busy schedules. One way to create “buy in” among senior managers is to get them involved in stakeholder engagement at a very early stage since those conversations generally uncover opportunities that senior management will be eager to integrate into their strategies.

People at all levels of the organizational hierarchy may be asked to take on new roles and responsibilities and, as noted earlier, the leadership team must be prepared to “make the case for change” and provide incentives to employees for wholehearted participation in the CSR initiative. Some of those incentives will be actual changes and improvements to the day-to-day experience of employees such as more training and mentoring opportunities and implementation of work–life balance policies. Other steps that should be taken to build employee support include involving employees in business decisions that affect them and improve the work environment. Particular attention should be paid to engaging middle management personnel, many of whom may be skeptical of the importance and relevance of CSR, and steps that should be taken include sharing the business case for proposed CSR actions with impacted middle managers to demonstrate how the actions will have a positive influence on the resources they oversee. The business case should also describe the support that middle managers can expect to receive to help them carry out their new CSR-related responsibilities.

Situation (“SWOT”) Analysis

Once the company has collected and screened all the relevant information about its external environment and its own internal resources, a thorough analysis should be undertaken to match the strengths of the company to opportunities in the business environment and identify weaknesses that are likely to create challenges to the company’s efforts to execute its strategies and attain its goals and objectives. One well-known and useful tool for this process is referred to as “SWOT analysis,” sometimes referred to as “situation analysis,” so named because it calls for systematic review of the company’s strengths and weaknesses and the opportunities and threats in the company’s business environment as a means for uncovering strategies that effectively leverage the company’s core competencies. In general, SWOT analysis involves the following five steps:

While all the steps in the SWOT analysis is important, the most crucial questions generally relate to whether or not the company is able to identify resources and other factors that can offer it a sustainable and reasonably protectable competitive advantage. An identifiable tangible or intangible asset, such as a patent or exclusive licensing arrangement, is certainly a good source of competitive advantage; however, it is important to think broadly at this stage to consider other possibilities that may be difficult to quantify. For example, a small emerging company often has an advantage over larger firms because of its ability to respond more quickly to opportunities in the marketplace. This “flexibility” advantage can and should be leveraged in a way that allows the company to quickly and efficiently introduce new products and services. Many emerging companies also derive a competitive advantage from the people that they attract to work for them and senior management should not ignore the role that the human resources function can play in creating and executing an effective strategy.

Weaknesses identified during the SWOT analysis should also be taken seriously and companies must be prepared to identify and implement significant changes to their strategy rather than continuing down a road that will ultimately be unsuccessful in light of the entrenched position of competitors or significant hurdles in the company’s external environment. Assume, for example, that the SWOT analysis indicates that a large competitor has been able to build a significant cost advantage based on proprietary technology that the competitor introduced after several years of development. Assuming that the company’s intellectual property position with the technology is strong it would make no sense for the company to attempt to compete on the basis of price or undertake a lengthy and expensive research and development program to create its own technology that would threaten the competitor’s position. In that situation the weakness in relation to the competitor dictates that the company should look elsewhere for its strategic initiatives. One possibility would be concentrating on new product lines where the competitor’s technological lead is not relevant and in which the company’s own competitive advantages can be fully exploited.

The value of SWOT analysis to the strategic planning process is that it forces senior management to fully understand the company’s external environment and critically evaluate the company’s own internal strengths and weaknesses. While companies often choose to leverage their strengths in areas where of the external environment where competition is sparse, there may also be situations where the information in the SWOT analysis clarifies that the company’s strengths are adequate to allow for head-to-head competition with other businesses for a piece of what is clearly the most profitable market available to the company at that time. SWOT analysis should also disclose opportunities for the company to make changes in its external environment that will make it easier to exploit its strengths. For example, the company may decide it is in its interest to proactively lobby for changes in applicable laws and regulations in a way that will open new market opportunities that fit well with the company competitive advantages. Before any strategy is set, however, the information from the analysis should be used to sketch out several alternative scenarios that can be evaluated and compared side-by-side.

Obviously SWOT analysis can contribute to the developing the most appropriate overall strategy for the company—one that aligns the company’s strengths (i.e., competitive advantages) to the most promising opportunities in the company’s external environment. The information collected during the SWOT analysis can also be quite valuable to the company for other reasons. For example, as the company learns more about its competitors, it can begin to establish benchmarks to compare its performance and resources in key areas against that of other firms. This provides opportunities for companies to learn and absorb best practices from other firms with regard to functional activities that can become the basis for a competitive advantage. In situations where the gap between the company and its competitors is extreme an important part of the company’s overall strategic goals and objectives may well be acquiring and deploying the resources necessary to close that gap. Benchmarking itself is a complicated mix of art and science and performance measures should be identified with respect to the efficiency of particular processes and the results obtained by the firm from using those processes.

Researching CSR Activities of Other Firms and Existing CSR Instruments

Information from research on CSR activities of other firms and existing CSR instruments should have been collected duringthe afore-discussed assessmentphase as a means for measuring how the company’s current CSR efforts compare to similar companies and recognized international standards and best practices. When attention turns to developing the CSR strategy, these same sources of information should be viewed as valuable precedents from others with substantial experience in the area and should be mined to identify the areas of greatest import and gather ideas that can be incorporated into the company’s own CSR strategy.⁴

The leadership team should closely assess the CSR activities of two types of companies: companies that operate in the same countries and markets (i.e., competitors) and companies that have gained a reputation for sound CSR practices even though they cannot reasonably be considered competitors of the company. In each case, the goal is to figure out what those companies are doing with respect to CSR and identify similarities and differences between those firms and the company. Information should be available from public statements regarding vision, values, and policies; codes of conduct; marketing materials for products and services and social responsibility reports prepared and published as part of the firm’s governance program. While other firms will not disclose all the details of their various projects, the leadership team should be able to get a good sense of the benefits, costs, and projected outcomes of a particular initiatives, assess how they might be implemented by the company, and identify key changes in organizational practices that will be needed in order for a comparable project to be launched.

Research on what other companies are doing should be carried out by members of the leadership team that already have operational experience in developing and implementing comparable CSR initiatives as they are the people best situation to “fill in the gaps” given that it is generally not feasible to get all the information necessary to fully understand what other companies are doing. Looking at what competitors might be doing makes sense from a broader strategic perspective since it is always important to be scanning the moves of other firms and it is generally easier to make comparisons with competitors since many aspects of their operational activities are similar and already known to the company. As for information from noncompetitive companies, the goal is to expand the leadership team’s knowledge of “best practices” and then figure out what specific lessons can be drawn and put to work in the company’s particular situation. Several organizations regularly publish lists of companies considered to be leaders in corporate responsibility and sustainability. In addition, information on best practices relating to CSR can be collected from industry associations and CSR specialist organizations such as the World Business Council for Sustainable Development (www.wbscd.org), Business for Social Responsibility (www.bsr.org), and the Conference Board (www.conference-board.org), all of which conduct research, hold conferences, and workshops and issue newsletters and other publications on CSR issues.⁵

Assessing the Relevance and Value of Voluntary CSR Instruments

Compliance with laws is a fundamental principle of environmental and social responsibility; however, much of CSR is based on aspiring to fulfill principles and standards that extend beyond what has been formally approved in a legislative or regulatory process. ISO 26000, promulgated by the International Organization for Standards, noted that an important and effective way to accelerate the implementation of CSR is by tapping into the resources and credibility of one or more of the many organizations that have developed voluntary initiatives and instruments, and even launched separate organizations, intended to help other organizations seeking to become more socially responsible. The goal of these initiatives has generally been to develop a consensus among disparate groups (i.e., governmental organizations, the business community, nongovernmental organizations, and other experts) regarding international norms and standards with respect to various areas that are commonly placed beneath the expansive umbrella of CSR.

According to ISO 26000, some of these initiatives address aspects of one or more core subjects or issues, while others cover various ways that social responsibility can be integrated into an organization’s decisions and activities and create or promote specific tools or practical guides that can be used for integrating social responsibility throughout an organization. Another common activity of these initiatives is the development or promotion of minimum standards and expectations regarding some aspect of social responsibility such as codes of conduct, recommendations, guidelines, declarations of principles, and value statements. These standards may be “universal” (i.e., applicable to all organizations) or sector-specific and thus tailored to unique conditions and issues in a particular sector. Some initiatives also involve the possibility of certification against the standards in the initiative by independent third parties.⁶

Annex A to ISO 26000 contains a nonexhaustive list of voluntary initiatives and tools for social responsibility that were identified by the ISO 26000 working group experts during the development of ISO 26000 using a specific set of criteria that is also described in Annex A.⁷ Annex A distinguished between cross-sectoral and sectoral initiatives (i.e., initiatives that have been developed by specific sectors such as agriculture, information technology, public services, tourism etc,). Three types of cross-sectoral initiatives were identified: “intergovernmental initiatives” (i.e., developed and administered by intergovernmental organizations, such as the UN Global Compact); “multistakeholder initiatives” (i.e., developed or administered through multistakeholder processes, such as the AccountAbility AA 1000 Series, the Ceres Principles, and Transparency International); and “single-stakeholder initiatives” (i.e., developed or administered through single-stakeholder processes, such as the Caux Round Table Principles for Business, and the World Business Council for Sustainable Development).

Many organizations find that attaching themselves to one or more of the well-known voluntary CSR initiatives is a good way to organize and announce their CSR commitments. For example, companies of all sizes have pledged their support for the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the United Nations Global Compact, ISO 26000, and other standards established by the ISO and the Global Reporting Initiative. Sector- and industry-specific codes and guidelines may also be available for companies depending on their line of business (e.g., tools, codes, and standards on sustainable development and CSR for the mineral exploration industry developed by the Prospectors and Developers Association of Canada). However, Section 7.8.2 of ISO 26000 made the point that it was not necessary for an organization to participate in any of the initiatives for social responsibility, or to use any of their tools, in order for it to be socially responsible, nor was participation necessarily a reliable indicator of the social responsibility of an organization.

Initiatives vary significantly with respect to their credibility in the eyes of stakeholders and many are generally perceived as being little more than a public relations scheme designed to protect the reputation of members as opposed to helping them make real progress toward social responsibility. Participation in any of these initiatives comes with a cost in terms of time, effort, and resources and organizations need to determine whether participation will be perceived as valuable by their stakeholders and provide them with access to practical guidance that can be readily used to drive implementation and integration of CSR. Section 7.8.3 of ISO 26000 includes the following list of factors that organizations should take into account when considering whether to participate in or use a CSR initiative⁸:

Developing and Prioritizing Options for Proposed CSR Actions and Activities

The assessment of the company’s current and potential CSR activities, combined with the survey of practices of other companies and guidelines included in CSR instruments, should allow the leadership team to start putting together a list of proposed CSR actions that can then be analyzed in light of the company’s immediate opportunities and threats and available resources. One approach to identifying and prioritizing proposed CSR actions is to begin by collecting and placing ideas into an L-shaped matrix: one dimension would be the main categories of CSR activities (i.e., environmental, social (e.g., workers, communities), and economic (e.g., quality assurance, customer satisfaction)) and the other dimension would be the element of the company’s activities that would be the focal point of the action (i.e., processes, such as upgrading registration and certification status; products and services such as focusing on product labeling and performance characteristics; and impacts such as increasing stakeholder engagement). Another important step is to hold brainstorming sessions with key internal and external stakeholders including members of the senior management team, employees, and representatives from key business partners and the surrounding community to understand their expectations, intensity of interest, and willingness and ability to contribute to strategy execution.

A different perspective can be gleaned from mapping the CSR landscape based on two dimensions—benefit to society and benefit to business—and then populating that map with suggested activities based on where they fall among four areas: “pet projects,” activities selected by individual executives based on their personal interests, are often supported by companies, yet typically have little benefit to either society or the business; philanthropy, which generally does well in terms of benefit to society but often provides little in the way of business benefit unless done strategically; “propaganda” activities that are primarily intended to enhance the company’s reputation but do not produce much in the way of social benefit and often put the company at risk for criticism if it appears that its actions are not as strong as it words; and “partnering” arrangements established to improve the company’s core value creation abilities, address long-term challenges to the company’s sustainability, and make an impact on important social issues such as improving employment, overall quality of life, and living standards. Mapping of this type highlights shortcoming in prior actions and illustrates how companies can shift the balance of their activities toward strategic philanthropy and high value and impactful partnering initiatives.

Another approach the leadership team should use to develop options for new CSR actions is to hold brainstorming sessions with key internal and external stakeholders including members of the senior management team, employees, and representatives from key business partners and the surrounding community. The foundation for these sessions should have been established during the dialogue that began in the assessment stage. While the agenda for the sessions might vary a good starting point would be to go through the following questions recommended by Hohnen and Potts⁹:

As previously noted, the brainstorming sessions can and should contribute to strengthening stakeholder relationships, engagement, and collaboration. In addition, the opportunity to participate in discussing what are often difficult issues builds commitment and excitement among those involved and makes it easier for participants to “take ownership” of the ideas and champion them throughout the organization once the time comes for implementation. Some companies use outside facilitators for these sessions in order to take advantage of their expertise in group dynamics and eliciting comments and provide a neutrality that ensures that the “agenda” of any one person or business unit does not skew the process and ignore other good ideas. Outside sources may be used to gather information necessary to answer some of the questions posed earlier. For example, while participants may have their own views about what are the most pressing social and environmental issues reference should also be made to publicly available surveys on the subject in order to get a better idea of stakeholder expectations and the likelihood of changes in regulatory and market attitudes.

Regardless of the approach that is taken by a company, the leadership team needs to remain focused on materiality in order to manage what will typically be a long list of potential ideas that, taken together, would overwhelm the company’s available resources if all of them were executed simultaneously. While many companies appears to have a wide range of programs that they proudly promote as indicators of their environmental and social responsibility—biking programs, recycling drives, and small philanthropic initiatives selected based on the preferences of the CEO— they fail to achieve the level of success they might have if they limited their efforts to a handful of impactful projects around material business and sustainability issues that can be clearly measured and explained to stakeholders. This does not mean that companies, particularly small businesses, should not bother with modest programs to get their feet wet; however, the long-term goal should be to undertake and realize dramatic and fundamental changes in business models, products, processes, and stakeholder relationships to incorporate socially and environmentally responsible principles.

Building the Business Case for a Proposed CSR Action

While CSR is grounded in the fundamental proposition that companies should look beyond economic performance to take into account the social and environmental impact of their activities, the reality is that “doing the right thing” is not a sufficient argument and CSR initiatives also need to make good business sense and be based on economic, environmental, and social goals that are achievable and that do not create undue risk to the survival of the company. All this means that the leadership team should be creating and evaluate a business case for each of the CSR ideas that a company is considering; however, research indicates that only about one in four companies that have decided to formally pursue a sustainability strategy have taken the extra time to establish the necessary business case. Among the companies that do take the time to develop a business case, many take a reactive approach and wait until it is necessary to respond to external pressures (i.e., “playing defense” and focusing their sustainability activities and investments on mitigating risk and other externalities, preserving reputation and regulatory compliance). The preferred assumption for building a CSR business case is that the investment should be perceived in the same way as any other opportunity, which means demonstrating how the project will increase market share, enhance efficiencies, and create a competitive advantage. Having a strong business case that has been rigorously vetted supports other key requirements for effective CSR including leadership commitment, employee engagement and interest, and clear goals and metrics that can be readily communicated and stakeholder engagement and support.

Deciding on Direction, Approach, and Focus Areas

Once the most promising and interesting CSR actions have been identified and business cases created for each of them, the leadership team needs to decide on the direction, approach, and focus areas of the CSR initiative. In many cases, a proposed action will be eliminated after the business case is completed and it is clear that undertaking the action is not feasible. The business case analysis will generally allow the leadership team to create a rough ranking of the proposals from an economic perspective; however, it is not always the case that these rankings are followed and an action that may not have as strong a business case as the others may still be selected because it fills a gap in building on a relationship with an important stakeholder group. Ultimately the choices must be based on the size and importance of the issue addressed by the proposed action, the chances of success for the proposed action, and the degree of difficulty in implementing the action, the amount of time that will likely pass before results are seen from the action, the financial and human resources required to effectively implement the action and the anticipated legal, political, technological, and cultural hurdles to implementing the action. In addition, consideration needs to be given to feasibility of support from outside parties. For example, many good ideas for developing countries are simply not viable unless and until local governments make improvements to roads and telecommunications.

Hohnen and Potts explained that the “direction” is the overall course that the company could pursue or the main areas it is aiming to address.¹⁰ While the answer to this question should be consistent with generally recognized values and standards (e.g., protecting human rights or the environment), it will also very company-specific. Examples of a “direction” include emphasizing worker health and safety; for pharmaceutical companies, focusing on health issues in developing countries; environmental issues associated with manufacturing processes; relations with surrounding communities; and implementing antibribery measures. The “approach” includes the steps that the company intends to take in order to proceed in the selected direction and might include revising its mission, creating and implementing new codes of conducts, employee communications, and training and engagement with supply chain partners. Finally, “focus areas” should be clearly aligned with the company’s business objectives and thus an immediate priority. Examples include changes in the company’s existing processes (i.e., that is, enhanced protection of personal information by a financial institution), investment in new opportunities (i.e., a bank launching microcredit programs in developing countries), and/or implementation of new programs to address critical needs of key stakeholders (i.e., a food retailer introducing new products to help customers in the battle with obesity).

There are a number of different ways to develop a “strategy” and the key point is that the parties involved need to have the skills and experience necessary, including knowledge about the company’ external environment, to develop a top-line sustainability approach, focus areas, and goals and targets (including a means for measuring progress toward achievement of the goals and targets). For example, on the section of its website relating to sustainability strategy (www.gesustainability.com) General Electric (GE) described its top-line sustainability approach as “investing in developing sustainable and environment-friendly products to drive revenue growth.” In executing its strategy, GE focused on three areas: developing a safe working environment, developing products that met customers’ needs, and supporting society through social activities. Specific goals and targets, which were measured and reporting on regularly, were established for workforce development and inclusiveness, governance, health and safety, health, energy and climate, water, charitable giving, volunteering, and investment in innovation.

Another example is provided by the public positions of Kellogg Company, which declared in 2012 that it was “devoted to producing great-tasting foods that people love, and to operating all aspects of our business safely and responsibly.”¹¹ Kellogg broke its global CSR strategies into four categories, each of which had their own issues:

Kellogg noted that the specific commitments within each of the categories were driven in large part by taking into account areas of importance for the company and its stakeholders and also helped form for the structure for internal reporting. According to Kellogg, “Our corporate responsibility strategy has been fully integrated into our business; subject-matter experts for each material area report on progress to the heads of their business units, who, in turn, report up through to a committee of our Board of Directors. In the past two years we have increased incentives for our executives to drive progress in certain corporate responsibility-related areas . . . [and] . . . we worked with our brand leadership teams to help better leverage our corporate responsibility activities in the brands’ engagements with consumers.”

The “Balanced Scorecard” Approach to CSR Strategy

Traditionally, performance measurement systems relied almost exclusively on management and cost accounting principles, often resulting in an emphasis on short-term results and efficient management of tangible resources (i.e., fixed assets and inventory), which were easier to measure using financial metrics, and failed to pay appropriate attention to non-financial intangible activities (e.g., nurturing of customer relationships, development of innovative products and services, and implementation of high-quality and responsive operating processes) that contributed to the creation of long-term value for the organization. The “balanced scorecard” (BSC) perspective was first advanced by Kaplan in the 1980s and is based on the premise that measurement of organizational performance should take into factors that are not purely financial and that organizations should use a management system that is better suited to communicating what they are trying to accomplish; aligning the day-to-day work that everyone is doing with strategy; prioritizing projects, products, and services; and measuring and monitoring progress toward strategic targets. Specifically, the BSC framework is a multidisciplinary view of organizational performance that includes measures such as market share, changes in intangible assets such as patents or human resources skills and abilities (e.g., employee learning and other aspects of so-called organizational capacity), customer satisfaction, product innovation, internal business processes (e.g., productivity and quality), stakeholder performance and potential value of future opportunities that have been created but which have yet to be realized financially.

Proponents of the BSC stress that the term “balanced” is not intended to imply equivalence among the various measures that are used in the framework but rather has been selected to ensure that users of the framework understand that not all key performance metrics are financial and that nonfinancial measures should be considered when looking for ways to improve long-term organizational performance and define and implement the organization’s vision, strategy, structure, reporting processes and training, and rewards programs. Not surprisingly, the BSC has been promoted as particularly useful for implementation of CSR initiatives given that the BSC framework explicitly incorporates and balances shareholder, customer, and employee perspectives and can be readily deployed using measurements along three dimensions of performance: economic, social, and environmental. Commentators have suggested that combining the BSC with CSR can and should begin with traditional financial measures and both expand the concept of financial to include CSR-driven market forces (e.g., “green” consumers and energy crunch) and broaden the performance dashboard to include the nonfinancial perspectives associated with the BSC and measured using qualitative and quantitative indicators and targets borrowed from the Global Reporting Initiative’s Sustainability Guidelines. This type of approach facilitates identification of new strategic opportunities that also score well in terms of CSR: insisting on supplier performance related to environmental and social commitments can not only improve quality of inputs but also attract and retain new customers that base their buying decisions on trust in the responsible business practices of vendors.

¹ Maon, F., V. Swaen and A. Lindgreen. 2008. Mainstreaming the Corporate Responsibility Agenda: A Change Model Grounded in Theory and Practice, 37. IAGLouvain School of Management Working Paper.

² Hohnen, P., and J. Potts, ed. 2007. Corporate Social Responsibility: An Implementation Guide for Businessi, 32–33. Winnipeg, Canada: International Institute for Sustainable Development.

³ Id. at 33.

⁴ One useful tool for researching CSR activities of other firms is Pivot Goals, which is a database of the sustainability goals of the world’s largest and leading companies (http://pivotgoals.com/about.php).

⁵ Hohnen, P., and J. Potts, ed. 2007. Corporate Social Responsibility: An Implementation Guide for Business, 35. Winnipeg, Canada: International Institute for Sustainable Development.

⁶ 2010. ISO 26000 Guidance on Social Responsibility, 83.. Geneva: International Organization for Standardization.

⁷ Id. at 86.

⁸ Id. at 84.

⁹ Id. at 38.

¹⁰ The discussion in this paragraph is adapted from Hohnen, P., and J. Potts, ed. 2007. Corporate Social Responsibility: An Implementation Guide for Business, 40. Winnipeg, Canada: International Institute for Sustainable Development.

¹¹ See Kellogg 2012. Corporate Responsibility Report, http://kelloggcompany.com/content/dam/kelloggcompanyus/corporate_responsibility/pdf/2012/2012_Kelloggs_CRR.pdf (accessed April 20, 2018).